PRIVACY POLICY AND PERSONAL DATA PROCESSING NOTICE
RECIQLO DOO BEOGRAD, Tax ID: 115347447, Company Registration Number: 22145061 (hereinafter: the Company), as data controller, is aware of the importance of personal data protection, therefore treats your personal data in accordance with applicable regulations governing personal data protection, including the Personal Data Protection Act of the Republic of Serbia (“Official Gazette RS” No. 87/2018, hereinafter “PDPA”) and the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
In order to ensure transparent processing of personal data, the Company provides basic information regarding personal data processing, personal data protection and the rights of individuals concerning personal data processing for the purpose of using the Internet service (hereinafter collectively: the Service) through this Privacy Policy.
This Privacy Policy is an integral part of the Company’s General Terms and Conditions.
1. Basic Terms
Personal data is any information relating to an identified or identifiable natural person, directly or indirectly, particularly by reference to an identifier such as a name and identification number, location data, identifiers in electronic communication networks or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural and social identity of that natural person.
Personal data processing is any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (hereinafter: processing).
Data subject is a natural person whose personal data is being processed.
Controller is a natural or legal person, or public authority which, alone or jointly with others, determines the purposes and means of processing.
Processor is a natural or legal person, or public authority which processes personal data on behalf of the controller.
Recipient is a natural or legal person, or public authority to whom personal data are disclosed, whether a third party or not, except for public authorities which may receive personal data in the framework of a particular inquiry in accordance with law and process this data in accordance with personal data protection rules relating to the purpose of processing.
Profiling is any form of automated processing used to evaluate certain personal aspects, particularly for analyzing or predicting aspects concerning a natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
Other terms used in this document shall be interpreted in accordance with the provisions of the Personal Data Protection Act, opinions and positions of the Commissioner for Information of Public Importance and Personal Data Protection (hereinafter: “Commissioner”) and GDPR.
2. Company information as controller and contact details of the data protection officer
Controller contact details:
RECIQLO DOO BEOGRAD, Milutina Milankovića 1Ž, Novi Beograd
The Company has appointed a Data Protection Officer whom you can contact regarding all matters related to personal data processing, as well as regarding the exercise of your rights prescribed by this law, in one of the following ways:
- by sending an email to: [email protected]
- by sending a written notice to the Company’s registered address: RECIQLO DOO BEOGRAD, Milutina Milankovića 1Ž, Novi Beograd
- by submitting a written notice directly at the Company’s premises marked “for Data Protection Officer”.
3. Types of personal data we collect
First, we collect data directly from data subjects for the purpose of registration on the website (portal) or on the Reciqlo mobile application
- Name and surname
- Email address
- Residential or temporary address
- Phone number
- Bank account number
- User password
We also collect data that you provide when creating a user account on the platform or Reciqlo mobile application and when posting ads on them. We may store and in special cases process data such as: name and surname, email address and phone number, as well as descriptions and photos of waste items you want to sell.
Furthermore, we may store and process in special cases data such as ads you have posted on Reciqlo and keywords you have used for searching.
During use of the platform or Reciqlo mobile application, we may collect and process data about devices from which you access the platform. This includes device brand and type, operating system and its version, unique device identifiers, as well as information about the internet network through which you access the platform.
When you access the Reciqlo platform, we may use technologies such as cookies and similar technologies to identify your internet browser, as well as to display advertisements. By using the Reciqlo platform, data may be automatically stored on your device, such as cookies and cache data, which enable easier and more efficient use of the platform.
4. Legal basis and purpose of data processing
Below are the legal bases and purposes of processing on which the Company processes your personal data, which may be:
The legal basis for processing data of portal or Reciqlo mobile application users is the consent of the data subjects. Consent is given by accepting this Privacy Policy during registration on the portal or Reciqlo mobile application. Once given, consent can be withdrawn at any time in one of the following ways: by submitting a request for consent withdrawal to the Company’s email, by sending a letter to the company’s registered address, or by submitting a letter directly at the Company’s premises marked “For Data Protection Officer”. Explicit consent is required for processing special categories of personal data that are necessary for providing certain services or products. Please note that if you withdraw your consent to personal data processing, we will not be able to provide you with the desired service.
Identification of our platform users through user accounts is necessary for the smooth operation of platform functions, such as posting ads and possible communication with other users. Identification involves collecting data about users’ IP addresses, which is a legal obligation according to Article 16 of the Electronic Commerce Act. If a criminal offense is committed using the Reciqlo platform, this identification protects the injured party, helps state authorities in discovering perpetrators and can contribute to resolving civil disputes.
The legal basis for data processing for the purpose of Service performance, or taking steps prior to entering into a contract, at the request of the data subject. Namely, data processing is necessary for concluding and performing the contract for using the Company’s services or for the Company to take certain steps before concluding the contract, and for the purpose of concluding contracts between different Service users. If you refuse to provide data necessary for this purpose, the Company will not be able to conclude a contract with you or provide you with the requested service, nor enable the conclusion of a contract with other users of the portal or Reciqlo mobile application.
The Company may process your personal data when processing is necessary to comply with legal obligations of the controller (for example: compliance with legal obligations of the controller prescribed by the Anti-Money Laundering and Terrorism Financing Act, for the purpose of fulfilling requirements of competent state authorities, etc.). For data processing that is necessary to comply with the law and fulfill prescribed legal obligations, consent of the data subject is not required.
When processing is necessary to protect your vital interests or vital interests of another natural person.
Situations when processing is necessary for the purposes of legitimate interests pursued by the controller or a third party. Namely, in certain cases processing is necessary for the purposes of legitimate interests of the Company or a third party, taking into account that the Company’s interests do not override the interests or rights and freedoms of the person whose data it processes. The Company bases data processing on legitimate interest, for example, in the following situations: monitoring and maintaining security in the Company’s business premises (video surveillance of business premises, visitor records), monitoring and maintaining security of IT systems and Company operations, initiating and conducting legal proceedings before state authorities to exercise the rights and interests of the Company or other persons, fraud prevention, etc. For data processing based on legitimate interest, consent of the data subject is not required, but they have the right to use legal mechanisms to exercise their rights at any time in the manner described in the section on Data Subject Rights.
The Company processes personal data only for the purposes for which the data was collected. The purpose for which the Company processes data depends on the type of services you contract with us, whereby all data is processed to fulfill the purpose for which it is collected (e.g., for the purpose of collecting the most favorable offers for waste purchase for you).
5. Recipients of your personal data
The Company has the right to disclose personal data and documentation relating to the person, as well as data related to concluded contracts with the person, to third parties, namely:
- Legal entities that purchase waste on the platform or Reciqlo mobile application managed by the Company, based on cooperation agreements that the Company concludes with such entities.
- Insurance companies and all other entities that, due to the nature of their work, must have access to such data, in accordance with relevant regulations.
- Entities with whom the Company has concluded a contract regulating the handling of confidential data, such as clients and business partners of the Company, based on user consent. By accepting this Company Privacy Policy, you agree that the Company may disclose your personal data, namely name, surname, phone number, residential address and email address, to third parties who make offers for purchasing waste that you have advertised on the platform or Reciqlo mobile application. To ensure that your data is handled lawfully, the Company has concluded appropriate contracts with third parties, such as clients and business partners of the Company, relating to personal data processing, whereby we have, among other things, provided for the obligation of third parties to handle your data exclusively in accordance with the Company’s instructions and this Privacy Policy, so that you, regardless of such processing, have rights guaranteed by law and this Privacy Policy.
- Authorities and entities to whom the Company is legally obliged to provide appropriate data, or entities to whom your data is disclosed for the purpose of fulfilling contracts we have concluded with you, or for the purpose of providing services for which you have engaged us.
- For litigation and security purposes: We may also disclose your personal data if required by law, or in our good faith that such action is reasonably necessary to comply with legal provisions, to respond to a legal request, or to protect the security or rights of the Company, its clients or the public.
- In case of merger or acquisition of all or part of the Company by another company, or in case RECIQLO DOO BEOGRAD sells or otherwise disposes of all or part of the Company’s business, the acquirer would have access to information held by the Company, which may include personal data, in accordance with applicable law. Similarly, personal data may be transferred as part of corporate reorganization, insolvency proceedings or other similar events, if permitted, and will be conducted in accordance with applicable law.
6. Transfer of personal data to another country or international organization
The Company processes your personal data in the Republic of Serbia. In certain cases, personal data may be transferred to other countries or territories of other countries. If this is the case, the Company will act in accordance with the provisions of the PDPA, or in accordance with the Decision of the Government of Serbia on the List of countries, parts of their territories or one or more sectors of certain activities in those countries and international organizations where an adequate level of personal data protection is considered to be ensured (“Official Gazette RS” No. 55/2019).
7. Personal data retention period
The Company processes personal data collected for the purpose of fulfilling rights and obligations from contractual relationships until the termination of that relationship, except in cases when the Company is obliged to keep data even after the termination of the contracted cooperation, until the expiration of the legal retention period or while there is a legitimate interest, or valid consent.
The Company will not keep your personal data longer than necessary and lawful by processing it exclusively for the purposes for which it collected the said data.
8. Processing of personal data of persons under 18 years of age
All personal data processing presented in this document applies exclusively to persons at least 18 years old. Use of the platform system and Reciqlo mobile application, as well as processing results, is prohibited for children under this age without consent of their parents/guardians. In case such processing occurs despite our reasonable efforts to prevent it, we will cease after we notice the fact that users are under the specified age.
9. Security of personal data processing
The Company hereby informs you that it continuously evaluates and improves applied security measures to ensure secure and protected processing of personal data.
10. Automated decision-making and profiling
Personal data referred to here may be subject to automated decision-making. In this case, the data subject has the right to contest decisions made in the automated decision-making process, explained in section 11 of this Policy.
11. Data subject rights
a. Right of access
The right of access means that the data subject can obtain information from the Company about whether their personal data is being processed and, if so, approval to access their personal data and receive information about processing. The Company will provide a copy of the personal data it processes upon request. For additional requests, the Company may charge a reasonable fee for administrative costs. If the request is submitted electronically and unless otherwise requested, the Company will provide information in electronic form.
b. Right to rectification, completion and erasure of data
The Company will, at the request of the data subject, rectify personal data that is inaccurate or complete incomplete data. The Company will, at the request of the data subject, erase their personal data if conditions prescribed by law are met (e.g., if the purpose for which they were collected is fulfilled, if consent for processing is withdrawn and there is no legal basis for processing). The Company cannot erase personal data: if their processing obligation is prescribed by law or processing is mandatory for reasons of protecting public interest (e.g., acting on orders of state authorities) or is necessary to protect the Company’s interests such as initiating, filing or defending legal claims (e.g., filing a lawsuit, etc.).
c. Right to restriction of processing
The Company will, at the request of the data subject, restrict processing of their personal data in cases prescribed by law.
d. Right to data portability
The Company will, at the request of the data subject, provide personal data in a structured, commonly used and machine-readable format (e.g., on computer) and enable them to transfer it to another controller without hindrance from the Company if the following conditions are jointly met: (a) processing is based on consent or is necessary for contract performance and (b) processing is carried out by automated means. This right also includes the possibility to request that the Company directly transfer personal data to another controller if this is technically feasible.
e. Right to withdraw consent
You have the right to withdraw your consent to personal data processing at any time, however, please note that withdrawal of consent does not affect the lawfulness of processing based on consent before your withdrawal.
You can withdraw your consent by submitting a request to revoke consent to the Company’s e-mail, by sending a letter to the Company’s headquarters address or by submitting a letter directly to the Company’s premises with the note “For the Data Protection Officer”.
If you withdraw your consent to the processing of personal data, we will not be able to provide you with the desired service.
f. Right to object
At any time, the data subject may submit an objection to the Company regarding the processing of personal data based on legitimate interest or which is necessary for the purpose of performing tasks in the public interest or exercising the powers prescribed by law of the Company. After submitting the objection, the Company will suspend further processing of these data, unless there is a legal basis for processing that outweighs the interests or freedoms of the data subject, or if the processing is performed for the purpose of initiating, submitting or defending against a legal claim (e.g. filing a lawsuit, counterclaim, etc.).
g. Right to challenge a decision made in the process of automated decision-making, including profiling
Within the business relationship between the Company and the Data Subject, and in order to fulfill the rights and obligations arising from it, the Company may process user and client data in whole or in part in an automated manner, in order to offer and provide services that meet the specific needs of the Data Subject, as well as in order to improve the business relationship of the Company with users and clients.
If he/she believes that his/her rights have been violated by a decision made in an automated decision-making process, the data subject has the right to challenge such a decision, to express his/her opinion and to request that the decision be reviewed with the participation of an authorized employee of the Company.
h. Right to complain to the Commissioner for Information of Public Importance and Personal Data Protection
The data subject has the right to file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection, if he/she believes that the processing of his/her personal data is carried out contrary to the provisions of the Law or other applicable regulations.
The exercise of the above rights is possible at any time. To exercise these rights, you can send a written request, dated and signed in printed format, to the following address: RECIQLO DOO BEOGRAD, ul. Milutina Milankovića 1Ž, Novi Beograd, by e-mail to our Data Protection Officer at [email protected], or by submitting a letter directly to the Company’s premises with the note “For the Data Protection Officer.”
Likewise, if you want to withdraw your consent given for direct marketing purposes, you have the option to use the “unsubscribe” option that is enabled in every marketing communication.
12. Obligation to provide data
Providing your personal data enables us to perform the service for which you have engaged us. However, if you refuse to provide us with any requested information – we will not be able to perform the service for which you have engaged us, nor will we establish a contractual relationship with you.
13. Amendments to these rules
The Company may change and update these privacy rules from time to time as needed. The Company will notify you of any significant or material change to these privacy rules and will ensure that the notification is made in a manner that ensures that you confirm it, for example by using the e-mail address you provided to us, or in any other appropriate manner that enables effective communication.
14. Contact
Any question regarding this document can be addressed to the person responsible for personal data protection issues in the Company, via the following contact information: [email protected].
Updated: 2025-10-21
