PRIVACY POLICY
1. Data Controller
DANILO ANĐUŠIĆ PR DA Basketball Camp, headquartered in Slavkovica, Street Brdo number 10, 14240 Ljig, identification number 67231848, tax identification number 113978470, contact phone number 00 381 64 377 0813, email address: danilo@andjusicshootingcamp.com (“DA Shooting Camp” or “Controller“) processes your data by the provisions of the Law on Personal Data Protection (“Official Gazette of the Republic of Serbia”, No. 87/2018) (“Law“) and provisions of other regulations governing this area, and as the Data Controller, has prepared this Privacy Policy to make the processing of your data and the data of your children transparent and understandable. This Privacy Policy explains how we collect, share, and use your data and the personal data of your children, as well as how you can exercise your rights to data protection.
This Privacy Policy applies to:
Terms not defined in this Privacy Policy have the same meaning as the terms defined in the Law.
2. Personal Data We Collect
2.1. Personal Data We Collect from You
Depending on how you use our Website or interact with the Controller, the information we may collect about you could include the following:
I Personal Data You Voluntarily Share with Us
If, as a parent/guardian, you fill out an application for your child’s participation in the camp via the Website, you will be required to provide us with the following categories of personal data:
For the assessment of the criteria for participation in the camp, we collect and process personal data of your child, such as date of birth, height, weight, player’s position, and health status. This information is forwarded to individuals involved in our professional staff to decide whether and which registered child to invite for participation. If you provide us with any other personal data during the camp registration process, the Controller undertakes to process them by this Privacy Policy and with legal provisions and internal acts.
If, as a parent/guardian of a child, you enter into or intend to enter into a contractual relationship with DANILO ANĐUŠIĆ PR DA Basketball Camp, we will process data necessary for the conclusion and execution of the contract for participation in the camp and/or necessary for taking actions, upon the request of parents/guardians, before the conclusion of the contract for participation in the camp. For example, we will need to process the contact information of parents/guardians (name, address for mail delivery, email address, and phone number(s)), information about the child player, i.e., the child who will be a participant in the camp (name, phone number, date of birth, height, weight, jersey size, player’s position, address data, child’s health information). In addition to the mentioned data, we may ask you to provide other personal data not listed above but necessary for the preparation or execution of the contract, as well as for the fulfillment of the Controller’s legal obligations, such as the following data: confirmation of a physical examination performed and a doctor’s certificate not older than 6 months confirming that the child is capable of physical activities held during the camp; information about the flight/transportation by bus, i.e., the date and time of the child’s arrival at the camp; copies of the passport of the participating child and one parent/guardian; health information, such as a list of allergies and medications used by the child; the latest photograph of the participating child; duly signed documentation for enrollment. In all other cases where the purpose of collecting personal data is not specified, you will be informed when you are asked to provide your data and the personal data of your child, the purpose, and the legal basis for such collection.
Providing your personal data and/or the personal data of your child is not a legal but a contractual obligation, in case you register your child for participation in the camp and/or sign a separate contract with the Controller for the participation of the child in the camp. Therefore, providing certain data listed in this Privacy Policy is a necessary condition for the conclusion of the contract for participation in the camp, and any potential refusal to provide any necessary data may lead to the impossibility of concluding and executing the contract.
II Personal Data We Collect Automatically
We note that this Website uses an SSL security certificate to securely collect and transmit data between users’ computers and servers. Data is sent using the HTTPS protocol. The HTTPS protocol enables encryption, authentication, and integrity of communication between users’ computers and servers, using cryptographic keys and SSL certificates. All data is sent and received in encrypted packets and is unreadable to third parties.
When you visit our Website, we may automatically collect certain personal data from your device. More specifically, the information we collect automatically may include information such as IP address, device type, unique device identifier, browser type, and broader geographic location (e.g., location at the country or city level). Additionally, we may collect information about how your device behaves on our Website, including pages you accessed and links you clicked on.
Collecting this information allows us to better understand visitors coming to our Website, where they come from, and what content on our Website interests them. This information is primarily collected through “Cookies” and similar tracking technologies. Under Article 160, paragraph 3 of the Law on Electronic Communications, the use of Cookies is permitted, provided that the user is provided with clear and complete information on the purpose of collecting and processing data by the law regulating the protection of personal data, and provided that the user is allowed to refuse such processing.
Cookies are data stored on a computer (or other device) of a website user (visitor to a website) that allows tracking and analyzing user behavior on the website. Cookies typically do not lead to the disclosure of the identity of a specific user. In cases where they identify a user, Cookies represent personal data, and therefore all points of this Privacy Policy apply to them.
On the Website, we use the following cookies for the following purposes:
When accessing the Website, you can adjust cookie settings and disable certain cookies. We do not store sensitive personal data such as your address, password, data about your credit or debit card, etc., in cookies. You can delete cookies at any time by changing settings in your internet browser – internet browser (Internet Explorer, Firefox, Chrome, Opera, Safari, etc.). You can delete stored cookies from your internet browser, although removing a particular cookie may result in reduced functionality of the Website. The Website also uses Google Analytics services (provided by Google Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA), which are also based on technology similar to cookie technology and are stored on visitors’ devices, all for qualitative and quantitative analysis of the use of the website itself. More information is available in the Google Privacy Policy, which is available via the following link: goo.gl/f1oVC8.
3. Representation of the Processing Process
The aforementioned personal data (of Website visitors, parents/guardians of camp participants, and camp participants) are processed by us as the Controller for the following purposes and on the following legal bases:
Purpose | Legal bases |
• to respond to your inquiries sent to the email address available on the Website; • to enable the registration of children for the camp; • to process the registration of a child for the camp. | • The processing is necessary for taking actions, at your request, before the conclusion of a contract (contract for participation in the camp), for the conclusion of a contract, and the performance of such a contract concluded with the parents/guardians of children. |
• to assess the fulfillment of the conditions for the participation of the registered child in the camp. | • Processing is necessary for taking actions, at your request, before the conclusion of a contract (contract for participation in the camp). |
• to align the skills and abilities of the child with the opportunities provided by the basketball camp. | • Processing is necessary for the performance of the contract concluded with the parents/guardians of the children. |
• to protect the safety and health of the children participating in the camp. | Processing is necessary to protect the vital interests of the children participating in the camp and for the performance of the concluded contract. |
• For the purpose of marketing promotion of the camp, as well as the children who are participants of the camp. | • In certain cases, for example, for the purpose of photographing or recording children for the promotion of the camp and the participants themselves, we may only process the data based on your informed consent as the parent of the child. You have the right to withdraw your consent at any time, without affecting the lawfulness of the information collected prior to that. |
On the Website, we use the following cookies for the following purposes: Essential cookies (essential cookies) enable basic functions of the Website, such as navigating the Website and accessing secure areas. The Website cannot function properly without these cookies; Performance cookies are used to improve the performance and operation of the Website but are not necessary for its use. For example, they store the language you have chosen or the area where you are; Analytical cookies help us measure how users interact with the content of the Website, which helps us improve your user experience; Marketing cookies are used to display ads that are closer to you and your interests. | • The legal basis for processing data collected through performance cookies, analytical cookies, and marketing cookies is your informed consent, which you give if you select the “I accept cookies” option in the “pop-up” window during your first visit to our Website. You have the right to withdraw your consent at any time, without affecting the lawfulness of the information collected prior to that. • The legal basis for processing data collected through necessary cookies is the legitimate interest of the Controller. |
4. How do we store personal data?
We take appropriate administrative, technical, organizational, and other measures to ensure an adequate level of protection for your personal data and/or the personal data of your children that we collect and process. When assessing whether the measures implemented are adequate and whether the level of protection is appropriate, we take into account the nature of the personal data we collect and the nature of the processing we perform, the risks associated with the processing of personal data, the costs of implementing protective measures, and other relevant circumstances in each specific case. Members of our team are trained and possess appropriate knowledge and understanding of the importance of protecting your data, especially the importance of protecting the personal data of your children.
5. Are there Data Processors and/or recipients of data and/or third parties?
There are situations when the Controller may provide the collected personal data to third parties, some of which are data processors, some are data recipients, and some may be third parties. A data processor, within the meaning of Article 4, paragraph 1, point 9) of the Law, is a natural or legal person, or a body, that processes personal data on behalf of the controller, while a data recipient is a natural or legal person, or a body, to whom personal data are disclosed, whether or not it is a third party.
We have established very strict procedures and measures aimed at detailed analysis, assessment, and verification of all data processors before establishing a business relationship with them. In this regard, we collect documentation, certificates, and references from data processors to ensure that the data processor will carry out the task for which they are engaged in an adequate, appropriate, and efficient manner.
The following are data processors with whom we may share information about you and/or your children:
Dana Processor | Role | Headquarters |
___________________ | Email services based on Cloud technology | USA |
Google, Inc | Analytics services | CA, USA |
Meta Platforms, Inc | Analytics and marketing services | CA, USA |
Ordinacija Fizio Vračar | Treatment of any sports injuries in participating children at the camp | Mihajla Gavrilovića 3, Belgrade, Republic of Serbia |
Catering ________ | Nutrition of camp participants | Republic of Serbia |
Generali Insurance | Basic insurance coverage for camp participants in case of hospitalization during the camp. | Vladimira Popovića 8, Belgrade, Republic of Serbia |
Kovilovo Resort d.o.o. Beograd (Palilula) | Accommodation for camp participants (for children who choose the package with included accommodation), which is also the location of the camp. | Zrenjaninski put 250, 11211 Belgrade, Republic of Serbia |
Photograph/videograph __________ | Photographing/recording during the camp (only for children whose parents have given explicit consent for the processing of data collected in this way). | Republic of Serbia |
By the Law and other relevant regulations, the Controller will, whenever objectively possible, conclude appropriate data processing agreements with processors, where all essential issues related to the processing activities performed by the processor are regulated, including its obligations related to that specific processing, while the Controller remains responsible towards the data subject. With processors such as Google, Inc., and Meta Platforms, Inc., the Controller concludes service provision agreements, which among other things regulate the processing of personal data.
Data recipients may also be state authorities authorized to access personal data or to whom such data may be disclosed, but solely to the extent and in the manner prescribed by law.
Recipients are obliged to access and process the data in a manner that respects their obligations prescribed by the Law and other applicable regulations.
6. International Transfer
Personal data may be transferred from the Republic of Serbia to other countries or international organizations only by the rules specified by the Law on Personal Data Protection, as well as other regulations governing this area. Therefore, your data may be transferred and stored outside the territory of the Republic of Serbia.
In such cases, we will only transfer your data to:
7. Data Retention Period
We do not retain your data and the personal data of your child longer than necessary to achieve the purpose for which they were collected or longer than the time for which we have your consent.
For example, if your child is not selected to participate in the camp after applying, your data and your child’s data will be automatically deleted.
If your child is selected to participate in the camp, we will process your data and your child’s data until the expiration of the contractual relationship, by the participation agreement concluded between us as the parent/child of the participant. For any subsequent processing of your child’s data for any other purposes not mentioned in this policy, we will request your reasoned and informed consent.
Exceptionally, if there is a need for the Controller to file, pursue, or defend a legal claim without fault, in connection with compensation for any damages or exercising other rights arising from the concluded participation agreement, the Controller will process your data and your child’s data for filing, pursuing, or defending such legal claim, and the legal basis for such processing will be the Controller’s legitimate interest.
8. Your Rights
As a person whose personal data we collect, and as a parent of a child whose data we collect for the above-mentioned purposes and based on the above-mentioned grounds, you have the following rights:
9. Amendments to Our Privacy Policy
The Controller may update the Privacy Policy to adapt to legislation and innovations, but this will not reduce the legal protection of the individuals whose data is processed. Amendments come into force on the eighth day from the date of publication on our Website. We advise you to periodically check the Privacy Policy for any changes.
We will seek your consent for all material changes to this Privacy Policy if and where required by applicable laws.
10. Who to Contact for More Information?
Regarding all issues related to this Privacy Policy and all issues related to the protection of personal data and the exercise of your rights, you can contact us by letter via email at danilo@andjusicshootingcamp.com and/or by filling out the Request for the Exercise of Rights regarding the processing of personal data, which you can download here, and sending the completed request to the email address danilo@andjusicshootingcamp.com or by mail to the address DANILO ANĐUŠIĆ PR DA Basketball Camp, Slavkovica, Street Brdo number 10, 14240 Ljig, Republic of Serbia.
We will respond to your request within 30 days, with possible extensions in special circumstances along with an explanation. If you are not satisfied with the response or do not receive a response within a specified period, you have the right to complain with the Commissioner for Personal Data Protection.
11. Entry into Force and Amendments to the Privacy Policy
This Privacy Policy comes into force on the eighth day from the date of publication (28.02.2024) on the website: https://andjusicshootingcamp.com/