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PRIVACY POLICY
This Privacy Policy describes how Users' personal data is collected and processed in connection with the TopolaSmart application and the bike-sharing system in the Municipality of Topola, in accordance with the Personal Data Protection Law of the Republic of Serbia and, where applicable, the EU General Data Protection Regulation (GDPR).
1. Data controller and partners' roles
Controller: Creative Sharing d.o.o. Požarevac, Danila Kiša 3, 12000 Požarevac, company registration number 21997021, Tax ID (PIB) 114265483, director Ivica Janošević. Contact for data protection questions: creativesharingdoo@gmail.com.
2. What data we collect
2.1. Data you provide upon registration
Identification and contact data: first and last name, contact details, and other data from the documentation completed during registration at the Tourist Organization "Oplenac" Topola.
Data on allocated points, i.e. the ticket (barcode).
2.2. Data collected automatically
Location data: the GPS location of the device and the bicycle during the ride, as well as route history. This is particularly sensitive data and is processed only to the extent necessary to provide the Service.
Ride data: the pick-up/return station, start and end time, duration, and the bicycle used.
Technical data: device model, operating system, application version, IP address, device identifiers, and logs.
3. Purposes and legal basis for processing
Provision of the free Service (registration, renting, ride tracking, records of points/tickets) — legal basis: performance of a contract, i.e. carrying out tasks in the public interest [to be aligned].
Security, prevention of misuse, protection of bicycles and property — legal basis: legitimate interest.
User support and complaint resolution — legal basis: performance of a contract / legitimate interest.
Analytics and system improvement — legal basis: legitimate interest or consent (for optional tools).
Sending notifications and marketing messages — legal basis: consent, which the User may withdraw at any time.
4. With whom we share data
The Municipality of Topola and the Tourist Organization "Oplenac" Topola — as partners in the system, within their established roles in processing.
Providers of IT and hosting services, maps, and analytics — as processors, on the basis of a data processing agreement.
Competent authorities — where there is a legal obligation to do so or in order to protect rights.
Data is not transferred outside the Republic of Serbia. If it is transferred, appropriate protective measures are applied (e.g. standard contractual clauses).
5. How long we keep data
We keep data only for as long as necessary for the stated purposes or as required by regulations. Indicative retention periods: registration data — for the duration of the account and 180 days after the cessation of use; ride and location data — [blank]. After the periods expire, the data is deleted or anonymized.
6. User rights
In accordance with applicable regulations, the User has the following rights with respect to their personal data:
the right of access to data;
the right to rectification of inaccurate data;
the right to erasure (the "right to be forgotten");
the right to restriction of processing;
the right to object to processing based on legitimate interest;
the right to data portability;
the right to withdraw consent at any time, without affecting the lawfulness of prior processing.
The User submits requests relating to these rights to the email creativesharingdoo@gmail.com or on the premises of the info center of the Tourist Organization "Oplenac" Topola, or to the email info@topolaoplenac.org.rs. The User also has the right to lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection.
7. Data security
The Controller and partners apply appropriate technical and organizational data protection measures (encryption in transit, access control, access logging, and other measures) in order to protect against unauthorized access, loss, or misuse.
8. Cookies and tracking technologies
The application may use device identifiers and similar technologies for functionality, security, and analytics. Consent is requested for optional technologies. Details are available in [blank].
9. Minors' data
The Service is intended exclusively for persons of legal age (18 years and older) and is not intended for minors. The Controller does not knowingly collect the data of minors.
10. Changes to the Privacy Policy
The Controller may update this Privacy Policy. The User will be notified of significant changes through the application, on the premises of the info center of the Tourist Organization "Oplenac" Topola, or by email. The date of the last change is stated at the beginning of the document.