Privacy policy

of General Logistics Systems Croatia d.o.o.

PROTECTION OF PERSONAL DATA – PRIVACY POLICE

I

INTRODUCTION

Identity and contact information of the Data Controller and Personal data protection officer

General Logistics Systems d.o.o. Belgrade(GLS Serbia) is a company whose founder is General Logistics Systems B.V., Amsterdam. GLS Serbia offers a reliable and high-quality package delivery service, as well as express delivery and additional logistics services.

If you want to contact the Personal data protection officer, please primarily use the e-mail address: dataprotection@gls-serbia.com. You can also contact us by writing via a parcel addressed to the Personal data protection officer at GLS Serbia:

Personal data protection officer at GLS Serbia

General Logistics Systems d.o.o.

Pančevački put 152P,

11060 Belgrade (Palilula)

Personal data

Under the Law on Personal Data Protection of the Republic of Serbia ("Official Gazette of RS", No. 87/2018), personal data is any data relating to a natural person whose identity is determined or identifiable, directly or indirectly, especially based on an identity mark, such as name and identification number, location data, identifiers in electronic communications networks or one or more features of its physical, physiological, genetic, mental, economic, cultural and social identity.

The person to whom the data relates

A natural person whose personal data is processed, i.e. whose identity has been determined or can be determined, and who visits or uses our website.

Sources of data protection rights and data confidentiality obligations

GLS Serbia processes data under the provisions of the Law on Personal Data Protection of the Republic of Serbia ("Official Gazette of the RS", No. 87/2018 - hereinafter: "Law on Personal Data Protection").

GLS Serbia provides postal services or contributes to the provision of such services, so in this regard, it is obliged to comply with the provisions of the Law on Postal Services ("Official Gazette of RS", No. 77/2019) and to ensure the inviolability of the confidentiality of letters and other means of communication. All employees of GLS Serbia have an obligation to respect the confidentiality of letters and other means of communication.

Data security

By implementing technical and organizational measures, all companies within the GLS group make the greatest efforts to protect personal data from loss or misuse. Personal data is processed exclusively in systems that are protected by appropriate security measures. GLS Serbia will, in accordance with the development of technological achievements, adapt security and measures for the protection of personal data to the greatest extent possible.

Date of storage of data

The controller keeps the data for the time necessary to achieve the purposes for which the data were collected and in accordance with applicable laws and regulations.

We retain personal data that we process on the basis of your consent as long as we have your consent to store and process them and for as long as it is necessary to perform the service. In the event of a security breach, we delete the data as soon as reasonably practicable. If consent is given for a specified period of validity, the data shall be deleted after the expiry of that period of validity as soon as reasonably practicable.

Personal data that we process on the basis of a legitimate interest is stored as long as there is a legitimate interest that is assessed on the basis of a test of legitimate interest.

We store some data (e.g. certain video material) for as long as the user of postal services can initiate complaint procedures in accordance with the Law on Postal Services (up to 6 months counting from the day after the delivery of the parcel), all on the condition that no complaint procedure has been initiated, which is why we must keep the data for evidential purposes.

You can certainly contact us with a question about whether we keep your data, for how long and why, and you can also request their transfer and deletion, i.e. you can use all your rights provided by the Personal Data Protection Act (see point IV - User rights).

II

COLLECTION, PROCESSING AND USE OF PERSONAL DATA WHEN SENDING SHIPMENTS

Categories of data, the purpose of personal data processing and legal basis

For the purpose of carrying out the service of sending a shipment, and thus fulfilling the contract with its clients - senders, in accordance with Article 5 paragraph 1 point 2 of the Law on Personal Data Protection, including the delivery of the shipment, payment of services, management of complaints, payment of taxes, customs duties, security measures and quality assurance, GLS Serbia collects data about the sender (address data, contact data, payment information and other relevant contractual data needed to perform the services ordered by the sender), as well as data about the recipient (name and surname, address, postal number, city, country, phone number and e-mail address).

Recipient data provided to GLS, as well as interface documentation (package scans at various locations) and Proof of Delivery (POD), may be processed and stored by GLS's subcontractors. GLS uses data about recipients only to the extent that it is necessary to fulfill the contractual obligation. Any further use is not permitted.

We may also receive your personal data (apart from you) from third parties - e.g. senders who send you shipments using our services, but also from other companies or services that may hire us.

Depending on the situation and the need, we also share data about the recipient and the sender with our subcontractors (warehouses, deliverers, contractual partners) to the extent necessary for the performance of the contracted service. In case of package damage/loss, data may be shared with the insurance company.

We also collect data about our partners (subcontractors, deliverers, warehouse managers and other partners). Before entering into a business relationship, but also during its duration, if the need arises, we are obliged to carry out background checks, such as compliance with provisions related to sanctions, checking of used vehicles, existing licenses and permits or other information, for which it is necessary to have appropriate personal data. We share the above data as necessary with external partners such as accounting services or legal advisors, all for the purpose of fulfilling contractual obligations, i.e. our legitimate interests.

If you are a candidate for a position in our company, we collect the data that you give us yourself, and we either delete it immediately after the end of the employment cycle or keep it (in the case of establishing an employment relationship) and possibly pass it on to an external partner in order to fulfill contractual obligations towards you as our employee.

We process data based on consent (based on Article 12 paragraph 1 point 1 of the Law on Personal Data Protection) or because of our legitimate interest (based on Article 12 paragraph 1 point 6 of the Law on Personal Data Protection).

We may also collect voice recordings made during a telephone contact with any of our customer service or other employees. If voice recordings are collected, we will definitely inform you at the beginning of the conversation itself. Voice recordings are collected to ensure the quality of our service.

We may occasionally contact you with questions about your preferences and opinions through surveys or through promotional offers, which is digital marketing that represents our legitimate interest.

Responsibility

Compliance with current regulations on the protection of personal data is the original obligation of every company within the GLS group. The transfer of data by the sender to the GLS company does not constitute data processing on behalf of others.

For additional services such as FlexDeliveryService and ShopDeliveryService, the e-mail address or phone number of the recipient is required to inform him about the status of the shipment. GLS companies receive phone numbers and/or e-mail addresses of senders who have ordered such additional services. The sender is responsible for the appropriate collection of such data and the recipient's consent to the transfer of their e-mail address and/or telephone number to GLS.

If you have any questions about this procedure, please contact your contractual partner (sender). You can also declare your withdrawal of consent to GLS Serbia. In that case, please use the contact information of the personal data protection officer within GLS Serbia. If you want to contact us by e-mail that is not encrypted, please take into account that the confidentiality of the information sent cannot be guaranteed. It is possible for such e-mails to be read by a third, unauthorized party. You can also contact us by sending a letter to the personal data protection officer.

Data sharing and recipients

As a rule, only the sender and recipient of the shipment are authorized to receive information about the package. GLS provides package information to third parties (e.g. competent authorities) only on the basis of binding laws. Therefore, in case of a legal obligation, we reserve the right to disclose data about you to competent state authorities, all in accordance with Article 12, paragraph 1 point 3 of the Law on Personal Data Protection, which stipulates that the processing is legal if it is necessary in order to comply with the legal obligations of the operator.

Companies within the GLS group do not sell or rent personal data to any third party. However, there are certain circumstances in which GLS may share your personal information by sending you additional notice. Persons who can receive your data can be:

  • GLS subcontractors and contractual partners in other EU countries or outside the EU for the purpose of delivering the shipment from the sender to the recipient (based on Article 63 of the Law on Personal Data Protection);
  • Affiliated or unaffiliated third parties who, based on the contract, provide services for or on behalf of GLS (Executives), especially IT service providers. GLS Serbia has concluded appropriate data protection agreements with those third parties;
  • other persons or organizations when permitted by applicable law or regulations;
  • The police, other personnel and national security agencies or as part of legal proceedings for the purpose of protecting our property or as part of an investigation related to violations of GLS rules and regulations, unauthorized access and/or use of GLS equipment or any other illegal activity.

III

COLLECTION, PROCESSING AND USE OF PERSONAL DATA WHEN USING OUR WEBSITES

Every time a user accesses GLS's website, data is stored in the so-called log file. The following specific data is temporarily stored:

  • IP number of the computer from which the request was made;
  • domain name;
  • date and time of access;
  • HTTP response code;
  • pages visited;
  • an operating system with version;
  • browser with version;
  • screen resolution.

In order to use the GLS pages, it may be necessary for the GLS servers to set the so-called cookies, which are used by the technical administrators of the website. Each visitor can configure their browser to refuse cookies. All visitors have the right to refuse cookies. Unless the user gives his consent, the cookie data will not be stored on the visitor's computer. In this case, the data stored in cookies will not be transferred to GLS. The functionality of specific parts of the website could be unavailable if cookies are disabled.

GLS Serbia distinguishes between open and closed areas for the use of the GLS website. The closed area is necessary for the fulfillment of the contract between GLS Serbia and its partners. Access is allowed only with the use of a username and password. In addition to other functions, the open area offers users an e-mail contact form, "Track and Trace". Data entered for the purpose of making inquiries via the e-mail form, such as first and last name, street, postal code, city, etc., we need them to process your inquiry. Your personal data will not be forwarded, sold or otherwise transferred to third parties.

The data from the log file are analyzed anonymously for statistical purposes. Statistical reports are used to evaluate the use of GLS websites. In particular, the schedule by which the pages are visited and the path made between them are shown.

Sending the newsletter

Until the withdrawal of consent, GLS Serbia has the right to send the newsletter to those users who previously agreed to send it to the e-mail address they provided. The database for the newsletter includes first and last name, e-mail address and time of consent or withdrawal.

Respondents have the right to withdraw their consent at any time by clicking on the link in the newsletter or sending a notification to info@gls-serbia.com, or contacting GLS customer service. The database for the newsletter is used exclusively for the purpose of sending the newsletter.

IV
USER RIGHTS

GLS Serbia respects the rights and freedoms of users. In accordance with the Law on Personal Data Protection, you have the following rights:

  • The right to request information about the processing of your personal data;
  • The right to access your personal data and the right to request a copy of it - according to the Law on Personal Data Protection, the data subject has the right to request information from the controller on whether he processes his personal data, access to such data, as and the following information:
  • on the purpose of the processing;
  • the types of personal data being processed;
  • the recipient or types of recipients to whom personal data have been or will be disclosed, and recipients in other countries or international organizations;
  • on the envisaged period of keeping personal data, or if this is not possible, on the criteria for determining that period;
  • the existence of the right to request from the controller to correct or delete his/her personal data, the right to restrict processing and the right to object to processing;
  • the right to file a complaint to the Commissioner for Information of Public Importance and Personal Data Protection;
  • available information on the source of personal data if personal data have not been collected from the data subjects;

  • The right to correct, supplement and delete your personal data, in which case we are obliged to act without delay upon receipt of a request for this type;
  • The right to limit their processing in case you dispute the correctness of the data;
  • The right to receive and transmit data in a structured, commonly used, and electronically readable format (the right to data portability - the right of a person to transfer data to another controller without interference by the controller to whom the data was provided if the processing is based on consent under the Law on the protection of personal data or based on a contract and if the processing is performed automatically);
  • The right to file a complaint against the processing of your personal data (if we base the processing on a legitimate interest or if we base it for direct marketing purposes, including profiling in these cases) and the right to terminate their processing;
  • The right to legal remedies provided by the Law on Personal Data Protection, including the right to file a complaint to the Commissioner for Information of Public Importance and Personal Data Protection and the right to judicial protection;
  • The right to withdraw consent for the processing of personal data (with the restriction that the withdrawal of consent does not affect the lawfulness of the processing that was performed before the withdrawal).

Exercising your rights

If you want to exercise your rights or withdraw your consent, please send a request to the personal data protection officer at GLS Serbia, and indicate which right you want to use so that GLS Serbia can take the necessary steps to respect your rights: dataprotection@gls-serbia.com

Please take into account that your revocation of consent to data processing, deletion of data and/or restriction of their processing may result in GLS Serbia, due to the nature of the service to be provided, possibly not being able to perform the contracted service. Also, your revocation of consent to data processing, deletion of data and/or limitation of their processing may possibly negatively affect the exercise of your rights that belong to you in accordance with the Postal Services Act (e.g. exercise of the right to object beyond the deadline).

Competent authority

The body responsible for data protection is the Commissioner for Information of Public Importance and Personal Data Protection of the Republic of Serbia, to whom you can file a complaint in accordance with the Law on Personal Data Protection.

You can contact the Office of the Commissioner at the address Bulevar kralja Aleksandra No. 15, 11 000 Belgrade, Republic of Serbia, or by e-mail: office@poverenik.rs or by phone: +381 11 3408 900 .