TOTAL IDEA is committed to protecting the rights and freedoms of individuals with regard to the processing of their Personal Data in accordance with the Serbian Law on Protection of Personal Data (Official Gazette of RS no. 87/2018) and EU GDPR. This Privacy Policy serves as a rulebook through which we would like to inform you about the personal information we collect, how it is processed and for what purpose.

Given the fact that the protection of individual’s privacy on the internet is vital for the future of all individuals that perform their activities on the internet and for opening the road to more widespread Real Internet Economy, TOTAL IDEA has drafted this Privacy Policy with a great desire to express its strong commitment to the rights of individuals regarding the protection and confidentiality of their Personal Data. This Privacy Policy covers how Personal Data can be processed.

TOTAL IDEA processes the Personal Data of individuals in accordance with this Privacy Policy. Any violation of this Privacy Policy can lead to TOTAL IDEA, as the Data Controller to be legally responsible for the consequences of that injury.

Α. GENERAL INFORMATION

Validity of this Privacy Policy.

This Privacy Policy applies to Personal Data which is provided originating from the lawful grounds described below. The use of any of the Personal Data collected from Cookies is subject to prior notification and consent of the Data Subject (you) in accordance with the Cookie Policy.

The Data Controller.

The Data Controller for https://total-idea.com/ and its content is TOTAL IDEA, 43a Svetozara Miletića, 21000 Novi Sad, Serbia, VAT 105012678.

Joint Controllers and Data Processors

TOTAL IDEA uses tools and software of GetResponse, with which TOTAL IDEA has a valid legal contract for processing Personal Data where processing is done on the grounds of performance of contract, on grounds of consent for content on the official website of TOTAL IDEA and based on our legitimate interest. GetResponse is a company based in Poland and is the Data Processor for the said processing whereas in these cases the Data Subject has all the rights according to the Serbian National Data Protection Law and EU GDPR (object to processing, transfer of data, copy of Personal Data etc.) which is in more detail explained in Section H below. Here are the links to GetResponse’s Privacy Policy and Terms of Service and here is the link to our Data Processing Agreement.

TOTAL IDEA has business partners with which it has established business collaboration in the service industry, these service providers are not performing those services on TOTAL IDEA’s exclusive request and they themselves determine how they process Personal Data, for the purpose of carrying out remarketing campaigns and statistical analysis.

In some cases, TOTAL IDEA may engage an external expert or contractor for completion and/or performance of contract with its clients, users and subscribers and in that case the external expert or contractor will have a separate Data Processing Agreement with TOTAL IDEA according to Serbian National Data Protection Law and EU GDPR.

What Personal Data does TOTAL IDEA collect?

• From visitors of website of TOTAL IDEA – IP address, internet service provider, geo location, country, type of device used to access internet, name of site that redirected you to TOTAL IDEA website, operating system and browser type.
• From subscribers to TOTAL IDEA content – IP address, geo location, name and surname, business name, website url, time of subscription and information regarding content and interest subscribers seek.
• From users and customers of TOTAL IDEA products and services – name and surname, address of residence, banking details, billing information, email address, IP address, geo location, gender, time of subscription and other additional information necessary for performance of services.

How does TOTAL IDEA use my personal data?

TOTAL IDEA will process the Personal Data provided below only as defined in this Privacy Policy. More information can be found in Sections B, C and D below, whereas information on processing of Personal Data by TOTAL IDEA based on performance of contract can be found in Section B below, information on the processing of your Personal Data based on your consent can be found in Section C below and information on the processing of your Personal Data based on our legitimate interest can be found in Section D below.

Duration of processing of personal data.

TOTAL IDEA processes and uses your Personal Data for the purpose of performance of a contract (see B below), based on your consent (see C below) and based on its legitimate interest (see D below).

• In case the legal ground for processing of Personal Data is the performance of a contract, TOTAL IDEA will store your Personal Data only for as long as contractual relations remain and, in any case, no longer than 5 years from end of contractual relations.
• In case the legal ground for processing of Personal Data is consent, TOTAL IDEA will process your Personal Data for a period of 2 years from the moment consent was given, after which you will be asked for consent again, and so on every 2 years.
• In case the legal ground for processing is our legitimate interest, TOTAL IDEA will process your Personal Data for a period that does not exceed the duration of its legitimate interest.

 

Additionally, TOTAL IDEA will stop processing your Personal Data if you have a valid objection and if you request so, or if you withdraw your consent (in cases that you have given your consent to TOTAL IDEA to use your Personal Data). However, whenever it is required as a legal obligation under the Serbian National Law on Data Protection and EU GDPR, TOTAL IDEA will keep your Personal Data for a longer period of time and whenever your Personal Data is required for TOTAL IDEA to claim or defend itself against legal claims, your Personal Data will be kept until the end of the corresponding retention period or until such claims are settled.

The use of this website by children.

This website is not intended for children under 15 years of age. If you are under 15 years old you may not use this web site without the prior consent of your parents or legal guardian.

Links to external web sites.

This website may contain links to other external websites. TOTAL IDEA is not responsible for the treatment of your Personal Data on other websites or for their privacy policy and the content of external internet sites. Therefore, we suggest that you carefully read the privacy policies of these external internet sites.

Application of the Privacy Policy.

Please note that this Privacy Policy applies to the processing of your personal data when you use any of TOTAL IDEA products or services, TOTAL IDEA web sites, as well as any of our product and service we offer together with our partners, which includes a link to this Privacy Policy.

EXPLICIT CONSENT

TOTAL IDEA is based in Novi Sad, Republic of Serbia and is under the authority and jurisdiction of the Serbian Data Protection Authority (DPA) and as the applicable law the Serbian Personal Data Protection Law which is why Data Subjects (visitors, subscribers, users and customers under Sections B, C and D below) give their explicit consent for use of their Personal Data in Serbia and are informed in advance of such use which they agree on. In case the Data Subject does not agree after already giving consent by submitting for content, conclusion of contract or expressing interest by sending its Personal Data to TOTAL IDEA, the Data Subject can at any time withdraw consent according to Section I below. TOTAL IDEA does not transfer Personal Data out of Serbia to third countries without your explicit consent.

Β. HOW TOTAL IDEA USES YOUR PERSONAL DATA FOR THE PERFORMANCE CONTRACT

In the following cases TOTAL IDEA is authorized to process your Personal Data in accordance with the current legislation on the protection of personal data in the Republic of Serbia and EU for performance of contract:

• If you establish a user account or become our client on the official website TOTAL IDEA in order to obtain content, which includes all content on TOTAL IDEA official website such as information, e-mails, newsletters, eBooks etc., TOTAL IDEA is authorized to process the following Personal Data: name and surname, address of residence, banking details, billing information, email address, gender, IP address, geo location business name, website url time of subscription and other additional information necessary for performance of the services and contract with you as the user. TOTAL IDEA will provide you with the opportunity at any time during the processing of Personal Data to clearly object to processing of personal data by TOTAL IDEA by submitting an e-mail on the official e-mail address at the end of this Privacy Policy. However, in cases where the retention of data is necessary due to legal obligations of TOTAL IDEA, then TOTAL IDEA retains Personal Data for a longer period of time but only during the existence of that legal obligation or when the personal data is needed for TOTAL IDEA to defend against a claim or lawsuit. To see the list of your full rights regarding our processing of your Personal Data please see Section H below.
• If you sign up to the mailing lists or express interest in receiving content from TOTAL IDEA which include all content on TOTAL IDEA official website such as information, e-mails, newsletters, eBooks etc., TOTAL IDEA is authorized to process the following Personal Data: name and surname, address of residence, banking details, billing information, email address, gender, IP address, geo location business name, website url time of subscription and other additional information necessary for sending and delivering such content. TOTAL IDEA will provide you with the opportunity at any time during the processing of personal data to clearly object to processing of personal data by TOTAL IDEA by submitting an e-mail on the official e-mail address at the end of this Privacy Policy. However, in cases where the retention of data is necessary due to legal obligations of TOTAL IDEA, then TOTAL IDEA retains Personal Data for a longer period of time but only during the existence of that legal obligation or when the Personal Data is needed for TOTAL IDEA to defend against a claim or lawsuit. To see the list of your full rights regarding our processing of your Personal Data please see Section H below.
• If you use our contact form to send us a message, we will use the information in the form only to respond to the question and contact you regarding your queries. The information you provide through our contact form will not be processed in any way and will only be used to communicate with regard to your questions and to provide additional answers if needed and will be retained only until that purpose is fulfilled.

C. HOW DOES TOTAL IDEA USE YOUR PERSONAL DATA ON THE GROUNDS OF YOUR CONSENT

In the following situations TOTAL IDEA will process your Personal Data in accordance with the current legislation on the protection of personal data in the Republic of Serbia and EU after consent is given to specific actions of processing.

• Cookies on TOTAL IDEA official website are small files that are installed on your device before you give your consent only in case of necessary Cookies and after your consent is given for all other Cookies i.e., analytics Cookies. The necessary cookies are necessary for the normal operation of the website of TOTAL IDEA. Analytics Cookies are used by TOTAL IDEA to provide content that best suits you and your interests. They can be used to send targeted ads/offers, limit ad impressions or measure the effectiveness of an ad campaign. They can also be used to keep track of the website you have visited to determine which online marketing channels are more effective and allow us to reward external websites and partners that promoted our website. Personal Data obtained in this way will be used for personalization of content and ads, to provide social media features and to analyse traffic. We also reserve the right, in the future to share information on how you use our website with our social media, advertising and analytics partners that can combine them with other information provided by you or gathered based on the use of other services with the aim of improving our services. TOTAL IDEA is authorized to process the following Personal data: IP address, internet service provider, geo location, country, type of device used to access internet, name of site that redirected you to TOTAL IDEA website, operating system and browser type. For more details about Cookies and how to turn them off visit Cookie Policy.
• Signing up and expressing interest in receiving content from TOTAL IDEA which include all content on TOTAL IDEA official website such as information, e-mails, newsletters, eBooks etc., TOTAL IDEA is authorized to process the following Personal Data: name and surname, address of residence, banking details, billing information, email address, gender, IP address, geo location time of subscription and other additional information necessary for sending and delivering such content. You can withdraw your consent at any time by sending an email to the official addresses of TOTAL IDEA as described in Section I below and TOTAL IDEA will immediately stop processing your Personal Data.

 

Necessary Cookies or Essential Cookies.

These Cookies are absolutely essential for the proper functioning of the website. They let you search the website and use its options. These cookies do not identify you. Without these cookies, our web site cannot function properly.

You can prevent the storage of cookies by selecting “Block cookies” in your browser settings. However, blocking all cookies might have a negative impact on the use of many web sites. If you still want to delete and disable cookies, you need to update the settings of your web browser (information on how to delete and disable cookies are available in your browser by choosing Help) or more information can be found at the following addresses:

• http://www.allaboutcookies.org/manage-cookies/
• http://www.aboutads.info/choices/

D. HOW DOES TOTAL IDEA USE YOUR PERSONAL DATA ON THE GROUNDS OF LEGITIMATE INTEREST

In the following cases TOTAL IDEA is authorized to process your Personal Data in accordance with the current legislation on the protection of personal data in the Republic of Serbia and EU when the legitimate interest exists:

• The legitimate interests of TOTAL IDEA provide a legal basis for processing for direct marketing purposes, provided that the interests or the fundamental rights and freedoms of the data subject are not overriding, taking into consideration the reasonable expectations of data subjects based on their relationship with the controller. Such legitimate interest exists where there is a relevant and appropriate relationship between the Data Subject and TOTAL IDEA in situations such as where the data subject is a client or in the service of TOTAL IDEA, i.e., when the Data Subject is a user/customer (Section B) or a subscriber of TOTAL IDEA (Section B and Section C). Such processing will be aimed strictly for direct marketing purposes and TOTAL IDEA is authorized to process the following Personal data: IP address, geo location, name and surname and information regarding content and interest subscribers seek for direct marketing purposes for content on social media platforms such as Instagram, Facebook and search engines such as Google.

E. PROTECTION OF DATA

In accordance with the level of technological advances, and the cost of their implementation, the nature, extent, the circumstances and the purpose of treatment, as well as the probability of occurrence of a risk and the risk level for the right and freedom of individuals, TOTAL IDEA implements the appropriate technical, personal and organizational measures in order to reach an adequate level of security in relation to the risk of data processing.

TOTAL IDEA protects your information using the following protective measures:

• Antivirus protection;
• 2 step verification process;
• Last pass manager;
• Encryption of Personal Data;
• Pseudonymisation of Personal Data;
• other appropriate technology and information protection.

 

TOTAL IDEA has taken appropriate measures to all systems, services, and equipment used for the processing of your personal data that meet acceptable standards of information security and protection of personal data. TOTAL IDEA carries out regular checks and scans in order to ensure that technical safeguards on hardware and software are functioning properly.

Access to personal data collected by TOTAL IDEA is provided only to those who have a legal basis for processing such as specific employees that have user access to the personal data which is stored only on a need-to-know basis. System of user access defines appropriate levels of access which each user has the rights to access the data stored. The system user access defines precisely what data the user has access to and if the user all can access the personal data and all the way in which they can be processed. In this case, users are employees and IT support. User access which is used by employees to comply with their roles in the business process in TOTAL IDEA and the descriptions of their operations are in accordance with the organization of business within TOTAL IDEA. Employees are given access only to those personal data which are necessary for the implementation of their necessary activities and do not excess those needs.

F. TRANSFER OF PERSONAL DATA

TOTAL IDEA does not transfer Personal Data to third countries. If the Data Subject has given explicit consent to transfer its Personal Data to another country, TOTAL IDEA does not in any case transfer Personal Data to any country other than the group of countries signatory to the Convention of the Council of Europe Convention on the Protection of Individuals with regard to Automatic Processing of Personal Data or countries that do not have an appropriate level of protection of personal data.

G. INFORMATION REGARDING THE WEB SITE OF TOTAL IDEA

This information applies only to our website at https://total-idea.com/. If you are redirected to other websites via links on our site, please inform yourself about the proper handling of your Personal Data on those websites, TOTAL IDEA is not responsible for processing of your Personal Data on any other website.

Built-in content from other websites

Articles and news on our website may include embedded content (e.g., videos, photos, articles, etc.). Built-in content from other websites that are not owned by TOTAL IDEA are to be considered in the same way as if the visitor has visited that web site and TOTAL IDEA is not responsible for processing of your Personal Data on any other website.

These websites may collect information about you using Cookies, install additional third-party tracking and monitoring your interactions with these embedded contents, including tracking of interaction with embedded content if you have an account and are logged into the site and TOTAL IDEA is not responsible for processing of your Personal Data on any other website.

Updates and changes of Privacy Policy

TOTAL IDEA may change this Privacy Policy at any time. If TOTAL IDEA makes changes to this Privacy Policy, it will notify you by publishing information here before the changes take effect and inform you directly of the changes before they come into legal force if you are a subscriber, user or customer.

H. YOUR RIGHTS

You have the following rights regarding the processing of your Personal Data:

• The right to request access, correction or deletion of your Personal Data of TOTAL IDEA.
• The right to request TOTAL IDEA to limit processing.
• The right of protest.
• The right to data portability.
• The right to withdraw consent at any time, except that revocation of consent does not affect the admissibility of processing based on consent before revocation.
• The right to submit complaints to the Serbian Data Protection Authority i.e., the Commissioner for Data Protection (contact details below).
• The right to information on whether the processing of your Personal Data, access to your personal data, information on the purpose of treatment, the types of data to be processed, the recipient or kind of recipients to whom the personal data is disclosed or will be disclosed and, in particular, to recipients in other countries or international organizations, the time limit of storage of personal data, or if that is not possible, the criteria for determining the time limit.

 

At your request, TOTAL IDEA will provide you with a copy of the data processed. TOTAL IDEA may request reimbursement of necessary costs for making copies of personal data which aData Subject required. If the request for a copy of personal data is submitted electronically, the answer will be delivered in a commonly used electronic format.

These rights can be enforced by contacting TOTAL IDEA in the following ways:
Address, Email, Telephone – Republic of Serbia, 21000 Novi Sad, Svetozara Miletića 43, Novi Sad, office@total-idea.com, DPO – Ivan Jovanović, 0637415614, office@total-idea.com.

I. WITHDRAWAL OF CONSENT

You may at any time withdraw the consent you granted by submitting a request through at office@total-idea.com. In this case TOTAL IDEA will no longer process any Personal Data subject to the consent unless legally required. It will be as if you never consented or gave TOTAL IDEA the Personal Data.

In the event that TOTAL IDEA is obliged to retain your Personal Data for legal reasons, your Personal Data will not be further processed and will only be retained for the period required by law. However, withdrawal does not affect prior processing of Personal Data by TOTAL IDEA until the time of withdrawal. In addition, if the use of TOTAL IDEA service/offer requires your prior consent, TOTAL IDEA will no longer be able, after withdrawal of your consent, to provide you with the relevant service, offer or event.

J. DATA PROTECTION AUTHORITY

The competent authority for the protection of personal data is the Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia. The Commissioner can be reached at the address Bulevar kralja Aleksandra 15, 11000 Belgrade, Republic of Serbia, e-mail: office@poverenik.rs  or by phone at +381 11 3408 900.

Data Protection Officer

Ivan Jovanović, 0637415614, office@total-idea.com