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Thank you for your interest in this Privacy Policy, and welcome to StudBud and our website located at www.studbud.org (our “website”)! This Privacy Policy sets out the basis on which we will process any personal Data that we may collect about you as a visitor to our website and user of our services. This policy further sets out how we protect your privacy and your rights in respect of our use of your Personal Data. 

WHO IS THE DATA CONTROLLER?

A “data controller” is a person or organisation who alone or jointly determines the purposes for which and the manner in which any Personal Data is, or is likely to be, processed. In this sense, StudBud of Adolfa Singera 12a, 24000, Subotica, Serbia (“StudBud”, “we”, “us”, “our”) is the data controller. If you have any questions about this policy or about data protection at StudBud in general, you can contact us by email using info@studbud.org with “Data Protection” in the subject line.

WHAT IS PERSONAL DATA?

Personal Data is information that makes it possible to identify a natural person. This includes, in particular, your name, date of birth, address, telephone number, e-mail address, but also your IP address. Anonymous data exists if no personal reference to the user can be made.

WHAT IS SPECIAL CATEGORY DATA?

Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data that, among others, concerns your health. In order to lawfully process Special Category Data, it is necessary to consent to the processing.

WHAT IS PROCESSING?

“Processing” means and covers virtually any handling of data.

WHAT LAW APPLIES?

We will only use your Personal Data in accordance with Serbia’s Personal Data Protection Law (“PDPL”), the EU’s General Data Protection Regulation (“GDPR”), and of course only as described in this Privacy Policy.

WHAT ARE THE LEGAL BASES FOR PROCESSING YOUR DATA?

The following informs you about the legal basis of us processing your data and unless the legal basis is not specifically mentioned, the following applies: 

Consent: This is where we have asked you to provide explicit permission to process your data for a particular purpose. 

Contract: This is where we process your information to fulfill a contractual arrangement we have made with you. 

Legitimate Interests: This is where we rely on our interests as a reason for processing; generally, this is to provide you with the best services in the most secure and appropriate way. Of course, before relying on any of those legitimate interests, we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.

Legal Obligation: This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime. 

Explicit Consent: In order to lawfully process special category data, we must identify both a lawful basis and a separate condition for processing, which typically is explicit consent.

WHAT PERSONAL DATA DO WE COLLECT FROM YOU?

We may collect and process the following Personal Data about you:

a) Personal Data that you give us

This is information about you that you give to us by filling in forms on our website, request information or correspond with us by telephone, post, email, or otherwise. It may also include, for example, your name, address, email address, and telephone number; information about your vehicle and our business relationship with us; and information about your requirements. The legal basis for processing is both our legitimate interest and the initiation of and, in certain circumstances, the fullfillment of a contract.

The protection of your Personal Data is particularly important to us in the performance of our contract with you and allowing you access to our services (“Service Data”). We therefore only want to process as much Personal Data as is absolutely necessary. Nevertheless, we rely on the processing of certain Personal Data, to fulfil our contractual obligations to you or to carry out pre-contractual measures and in the context of administrative tasks as well as the organisation of our business and compliance with legal obligations, such as archiving. The primary record relating to your Service Data is held by us and in your athlete profile. The Service Data we hold typically consists of the following:

  • Profile Details
    • Full name
    • Email address
    • Password
  • Identity
    • Full name and title
    • Preferred name
    • Gender
    • Date of birth
    • Nationality
    • Country of birth
    • Country of domicile
    • Passport details
    • Visa details
  • Contact details
    • Full postal address
    • Telephone number(s)
    • Email address
    • Next of kin details
  • Education information
    • Current school, and school year
    • Previous school history
    • Course of interest
    • Intended year of entry
    • Full qualification history
  • ‘Special category’ or sensitive information
    • Medications taken and current medical treatments, where applicable
    • Allergies
    • Additional requirements to enable reasonable adjustments
    • Criminal convictions (required for certain courses)
  • Information relating to your studies
    • A record of your application to the university, including information obtained from other organisations involved with your application.
    • Details of your courses, enrolments,
    • Proceedings of any academic or professional conduct investigation or assessments
    • Where relevant, records of any non-academic disciplinary proceedings or investigations
    • Records of your attendance and engagement with academic systems and services
    • Where applicable, information relating to your placements, student internships, and study abroad. 
    • Financial information collected for the purposes of administering fees and charges, loans, grants, studentships and hardship funds
    • Details of any sponsors supporting your studies. This does not include third parties (such as parents) who may be paying for your studies but with whom no formal contract exists
    • Records of and relating to travel, including passport and insurance details (where relevant)
    • Any further biographical information, such as academic qualifications, that you have entered into a university system yourself, such as those used to populate a profile page
  • Other information
    • Responses to voluntary surveys that you have submitted
    • Information provided by you in relation to any university
    • Records of university non-course-related events or training that you have attended and/or participated in
    • Records relating to your residence in university accommodation, where applicable
    • Information you have submitted to online learning and personal development and wellbeing platforms, where we legitimately have a right of access to this data

Why we need to use your information

  • To provide our Services to you
  • Assessment of your academic and athletic background.
  • Identification of suitable colleges and universities offering scholarships.
  • Guidance on the application process, including essay writing and documentation.
  • Assistance with communication and negotiation with potential institutions.
  • Assistance with visa application.

Generally, our legal basis for processing your Service Data is that it is necessary for the performance of the contract between you and us. We also have some activities that are in our legitimate interest, or require your consent to carry out, and some that we are legally obliged to undertake.

We recognise that you own your Service Data and provide you with complete control of your Service Data by providing you the ability to (i) access your Service Data, (ii) share your Service Data through supported third-party integrations, and (iii) request export or deletion of your Service Data. 

We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and protection safeguards strictly.

We process your Service Data as Data Processor or in other words on behalf of you, and will only do so in accordance with your instructions and use it only for the purposes agreed between you and us. We also take appropriate legal precautions and corresponding technical and organisational measures to ensure the protection of your Service Data. For further information, please also refer to our Data Processing Addendum.

If you are providing us with Personal Data relating to a third party, you agree a) that you have in place all necessary appropriate consents and b) that such third party has read this Privacy Policy. You agree to indemnify us in relation to all and any liabilities, penalties, fines, awards, or costs arising from your non-compliance with these requirements.

Within the Testimonial section, we may display certain personal information, share certain details, knowledge and insights. When you approve and submit your Testimonial to us your consent is obtained, and you have choices about the information in your Testimonial. The storage of Testimonials is based on your consent . You can revoke your consent at any time. For this purpose, an informal communication by e-mail to us is sufficient. The legality of the data processing operations already carried out remains unaffected by the revocation.

If you apply for a role or job, we process the information we receive from you as part of the application process. Your data will initially be processed using the Zoho Recruit Service from Zoho solely for the application process, and if your application is successful, it will become part of your personnel file. As a rule, we do not require any Special Category Data for the application process. The legal basis for processing data during the application process is the initiation of a contract and, if you have given your consent, for example, by sending us information that is not necessary for the application process, it is consent. 

If you make a payment, your payment data will be processed via our payment service provider, PayPal. Payment data will solely be processed through the by you selected payment service provider, and we have no access to any payment data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract.

For booking a Meeting in an easy and convenient way, we use TidyCal. Your data from the form will be transferred to our appointment account at TidyCal after you press the “Book appointment” button. You will then receive a confirmation email with a link to the event. Your data will be kept at TidyCal until the purpose for storing the data no longer applies (appointment made) or you request us to delete it. The legal basis is your consent as well as our legitimate interest.

Finally, we process data in the context of administrative tasks as well as organisation of our business and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest. 

b) Personal Data that our website and other systems collect about you

If you visit our website, it will automatically collect some information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and some other information, such as the pages on our site that you visit. This is used to monitor the performance of the website and improve the experience of visitors to the website. 

We use the hosting services of Cloudways, for hosting and displaying our website. Cloudways does this on the basis of processing on our behalf, which also means that all data collected on our website is processed on Cloudways’s servers. The basis for processing is our legitimate interest and the initiation and/or fulfillment of a contract. 

We also use the open-source Content Management System (CMS) of WordPress.Org to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to us are transferred to Cloudways and that your contact and contract data and your usage data are stored on Cloudways’s servers. The legal basis for this processing is our legitimate interest.

We have integrated Google Fonts by Google, and Font Awesome of Fonticons Inc. To enable the display of fonts, a connection to Font Awesome’s and Google’s server is established when our website is accessed. This enables Google and Fonticons to determine which website sent the request and to which IP address the display of the font is to be transmitted. The integration is based on our legitimate interest.

We have integrated videos from YouTube (Google). The integration requires that YouTube can perceive the IP address of the user. The IP address is required in order to send the video content to the user’s browser. If you click on a YouTube video on our website, your internet browser will be prompted to download a corresponding representation of the video and also places certain cookies. In this way, YouTube knows which specific sub-pages you have visited. The legal basis for the data processing is our legitimate interest and your consent.

c) Cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. As set out in the PDPL and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of non-essential cookies. For further information on the cookies we use, please refer to our Cookie Policy.

Our website uses the cookie consent tool to obtain your consent to the storage of certain cookies on your end device or to the use of certain technologies and to document this consent. When you enter our website, the following personal data is transferred to us: your consent(s) or revocation of your consent(s), your IP address, information about your browser, information about your terminal device, and the time of your visit to our website. The legal basis for processing is our legal obligation. 

d) Analytics

For business reasons, we analyze the data we have on web and server traffic patterns, website interactions, browsing behavior, etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and/or anonymised values (“Aggregated Data”). Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy. For this purpose we use Google Analytics from Google. The legal basis is our legitimate interest and your consent. For further information on our use of Google Analytics, please refer to our Cookie Policy.

OTHER USES OF YOUR PERSONAL DATA

We may also collect, store, and use your Personal Data for the following purposes:

  • to operate, manage, develop, and promote our business and, in particular, our relationship with you and related transactions, including, for example:
    • marketing purposes (when we have either gathered prior opt-in consent and/or have a legitimate interest to send you communications which we believe to be relevant and of use to you); 
    • to operate, administer, and improve our website and other aspects of the way in which we conduct our business;
    • to offer you our services;
    • to provide you with services or information that you may have requested; and
    • to keep you informed and updated on relevant topics or services you may be interested in.
  • to protect our business from fraud, money laundering, breach of confidence, theft of proprietary materials, and other financial or business crimes; 
  • to comply with our legal and regulatory obligations, bring and defend legal claims and assert legal rights; and
  • if the purpose is directly connected with an assigned purpose previously made known to you.

We will only process your Personal Data as necessary so that we can pursue the purposes described above and where we have a legal basis for such processing. Where our lawful basis for processing is that such processing is necessary to pursue our legitimate interests, we will only process your Personal Data where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest. In exceptional circumstances, we may also be required by law to disclose or otherwise process your Personal Data. 

CHANGE OF PURPOSE

We will only use your Personal Data for the purposes for which we collected it as detailed above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so.

DATA SHARING

In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.

Internal

If necessary, we transfer your Personal Data within StudBud. Access to your Personal Data is only granted to authorised employees who need access to the data due to their job, e.g., to provide our products or services or to contact you in case of queries. 

External bodies

Personal Data is transferred to our service providers in the following instances:

  • in the context of fulfilling our contract with you,
  • to use marketing services and to advertise our products and services online,
  • to communicate with you,
  • to provide our website, and 
  • to state authorities and institutions as far as this is required or necessary.

International transfers 

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements including non-disclosure agreements, data processing agreements, and standard contractual clauses regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will delete your Personal Data when we no longer need such Personal Data, for instance, where:

  • it is no longer necessary for us to retain your Personal Data to fulfil the purposes for which we had collected it; 
  • we believe that your Personal Data that we hold is inaccurate; or 
  • in certain cases where you have informed us that you no longer consent to our processing of your Personal Data.

Sometimes, however, there are legal or regulatory requirements which may require us to retain your Personal Data for a specified period, and in such cases we will retain your Personal Data for such specified period; and we may need to retain your Personal Data for certain longer periods in relation to legal disputes, and in such cases we will retain it for such longer periods to the extent required.

DATA SECURITY

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need-to-know access, to ensure the most complete protection of Personal Data processed through our website. 

SOCIAL MEDIA

We are present on social media based on our legitimate interest. If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint responsibility agreement. The Personal Data collected when you contact us is used to process your request, and the basis for this is both your consent and our legitimate interest.

MARKETING

Insofar as you have given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to. Our marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us or by our contracted service providers. Every directly addressed marketing sent by us or on our behalf will include a means by which you may unsubscribe or opt out.

LINKED SITES

For your convenience, there may be hyperlinks on our website that link to other websites. We are not responsible for, and this Privacy Policy does not apply to the privacy practices of any linked websites or of any companies that we do not own or control. The website links may collect information in addition to the information we collect.

We do not endorse any of these linked websites, their products, services, or any of the content on their websites. We encourage you to seek and read the Privacy Policy of each linked website that you visit to understand how the information that is collected about you is used and protected.

YOUR RIGHTS AND PRIVILEGES 

Privacy rights 

You can exercise the following rights:

  • The right to access;
  • The right to rectification;
  • The right to erasure;
  • The right to restrict processing;
  • The right to object to processing;
  • The right to data portability;

Update your information and withdraw your consent 

If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to legitimate interest processing, please do so by contacting us.

Access Request 

In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

What we do not do

  • We do not request Personal Data from minors and children without obtaining prior parental or legal guardian consent;
  • We do not process special category data without obtaining prior specific consent;
  • We do not use automated decision-making, including profiling; and
  • We do not sell your Personal Data.

Who is the competent data protection authority?

The Commissioner for Information of Public Importance and Protection of Personal Data (Poverenik za informacije od javnog značaja i zaštitu podataka o ličnosti) (“CIPIPPD”) in Serbia. If you believe that the processing of your Personal Data is not lawful, you can lodge a complaint with a data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the CIPIPPD or any other supervisory authority.

Data Breaches and Notification

Databases or records containing Personal Data may be breached accidentally or through unlawful intrusion. As soon as we become aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notification will be accompanied by a description of the measures that will be taken to repair the damage caused by the data breach. Notifications will be sent as soon as possible after the violation is discovered.

HELP AND COMPLAINTS

If you have any questions about this policy or the information we hold about you, please contact us using info@studbud.org with “Data Protection” in the subject line.

CHANGES

The first version of this policy was issued on Friday, 8th November, 2024, and is the current version. Any prior versions are invalid, and if we make changes to this policy, we will revise the effective date.