Privacy Policy and Terms of Use
Current version published on: April 21, 2023
1. General Information
1.1 This Privacy Policy explains how THE LAND OF STRATEGIST D.O.O. (the “Administration”), located at Omladinskih Brigada 53, Belgrade, Serbia, with registration number 21818194, collects and processes your personal data when you use the website www.integralway.eu (the “Site”) to protect your privacy rights.
1.2 The Administration will comply with all applicable data protection laws, including the General Data Protection Regulation (GDPR), and will respect your privacy rights.
1.3 By using the Site, you agree to the Administration’s collection, use, storage, and processing of your personal data as described in this Privacy Policy.
1.4 The Administration may collect and process personal data, including but not limited to: collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, depersonalization, blocking, deletion, and destruction of personal data.
2. Types of Information Collected
The information collected and processed by the Administration includes:
2.1 Personal information that you provide voluntarily, such as your name, email address, phone number, payment information, and other data.
2.2 Technical and statistical information, including your computer’s IP address, location and time of access, and information provided by your browser, such as device type, browser version, operating system, referrer data, etc.
2.3 Information about your actions on the Site, such as pages visited and links clicked.
3. Ways of Collecting Information
3.1 Feedback Forms on www.integralway.eu
3.1.1. Users can access the site without registering. Before sending a message or request, the user is prompted to provide their name, surname, address, phone number, and email address for further communication about the topic of the message.
3.1.2. In this case, the user provides the data voluntarily, and the legal basis for processing the data is consent. If the user does not agree to the processing of their data, the administration will not be able to process the user’s request.
3.2 Cookie Files
3.2.1. The site www.integralway.eu uses cookie files, which are necessary for users to use the site, for providing some basic functions, and for improving the website’s functionality.
3.2.2. What is a cookie file? A cookie file is a text file that is sent and saved on a user’s computer by the websites that the user visits. Cookie files are stored in the user’s browser’s file directory. If a user has visited a website before, the browser reads the cookie file and sends this information to the website or element that originally saved the cookie file. Additional information about cookie files can be found on the website https://www.aboutcookies.org/. Cookie files allow for tracking website usage statistics and the popularity of various sections and other actions on the website. Information obtained through cookie files is used to make the website more user-friendly and improve its content.
3.2.3. Users have the right to refuse to save cookie files on their computer. If a user wishes to opt-out of cookie files, they must change their browser settings, but they should note that some site features may become unavailable.
3.3 Google Analytics
3.3.1. The site www.integralway.eu uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files placed on a user’s computer, to analyze how Users use the website. Information created by this cookie file through the use of the website by the User (including IP address) will be sent to and stored by Google on servers in the United States. Google will use this information to evaluate the use of the website, compile reports on website activity for the website owner, and provide other services related to website activity and internet usage.
3.3.2. Google will not link a User’s IP address with any other data stored by Google. Additionally, information about the user’s IP address is anonymized before analysis. In order to use Google Analytics, the administration does not process or transmit to Google any information that allows for the identification of the user.
3.4. Facebook Pixel
3.4.1. The website www.integralway.eu uses the Facebook Pixel tool from Facebook Inc., located at 1601 South California Avenue, Palo Alto, CA 94304, USA (“Facebook”). The Facebook Pixel allows tracking of user behavior, such as interactions with Facebook ads and the website or redirects to www.integralway.eu by clicking on Facebook ads. This process is intended to evaluate the effectiveness of advertising on Facebook for statistical data and market research purposes and can help optimize future advertising campaigns. The data collected is anonymous, so the administration cannot identify the user based on it and does not send personal data to Facebook.
3.4.2. The browser automatically establishes a direct connection to the Facebook server. The administration does not influence the volume and further use of data collected by Facebook using this tool. Facebook continues to use your data in accordance with Facebook’s Data Use Policy: https://www.facebook.com/about/privacy/.
3.4.3. You can disable this feature at the following link: https://www.facebook.com/settings/?tab=ads#.
3.5. Google Tag Manager
The website www.integralway.eu uses the Google Tag Manager (GTM) tool. This service allows management of website tags through an interface. GTM only installs tags, which means it does not use cookies or collect personal data. GTM launches other tags that collect data as needed. If deactivation is performed at the domain or cookie level, it remains valid for all tracking tags installed using GTM.
4. Processing of personal data
4.1. The Administration processes personal data with the User’s consent, both independently and with the involvement of third parties.
4.2. Processing of personal data of the User begins from the moment of their receipt.
4.3. Storage and use of personal data:
4.3.1. The User’s personal data is stored properly and exclusively on secure electronic media and processed using automated systems, except in cases where non-automated processing of personal data is necessary in accordance with Serbian law.
4.3.2. When processing the User’s personal data, the Administration ensures the use of databases located in Serbia.
4.3.3. The period of storage of the User’s personal data on the Administration’s server begins from the moment of their receipt and ends at the moment of the complete deletion of the account.
4.4. Transfer of personal data. The Administration does not transfer personal data to third parties without the User’s consent, except in cases where the information is publicly available or the transfer is made:
4.4.1. To ensure compliance with Serbian law, prevent unlawful actions of the User, and protect the legitimate interests of the Administration and third parties.
4.4.2. At the request of government agencies in compliance with Serbian law.
4.4.3. To service providers for the purpose of fulfilling obligations under the relevant contract, provided that they comply with the conditions for processing personal data set out in the Privacy Policy.
4.5. Blocking of personal data. The Administration reserves the right to temporarily suspend the processing of personal data (except in cases where processing is necessary to clarify personal data).
4.6. Destruction of personal data. The Administration may destroy the User’s personal data in the following cases:
4.6.1. In the event of a threat to the security of the Site;
4.6.2. In case of violation of the provisions of Legal documents by the User;
4.6.3. Upon request of the User, sent to the Administration’s email address.
5. Purposes of personal data processing
5.1. The purpose of processing User’s personal data is to properly fulfill the obligations of the Administration to the User.
5.2. The User agrees that the Administration may use their personal data for the following purposes:
5.2.1. Transfer of personal data to payment systems and payment intermediaries when making payments within the Site’s functionality;
5.2.2. Implementation of partnership and other programs related to the distribution of advertising information by email, phone and other possible means;
5.2.3. Comparison of personal information to confirm its accuracy and verification by third parties in cases provided for by law;
5.2.4. Prevention of fraud and other abuses, as well as for investigating such cases;
5.2.5. Conducting statistical and other research based on anonymized data;
5.2.6. Resolving disputes, collecting feedback, and identifying malfunctions;
5.2.7. Improving the quality of the Site’s operation, convenience of its use, and developing new functionality.
6. Measures to protect personal data
6.1. Access to user data in the Administration’s services is protected by a password, and all transaction data is encrypted using SSL when exchanged between web browsers and services.
6.2. Access to data is limited to a minimal circle of persons who are responsible for processing the data, and processing is restricted to actions necessary to achieve the processing objective. Data is stored in a form that only allows identification of the individual for the period necessary to achieve the processing objective.
6.3. To protect the data stored on servers, the Administration regularly monitors the system for possible vulnerabilities and attacks and uses the highest level of access security to the data processing center.
6.4. The site may contain links to other websites that are not owned or operated by the Administration. Such links are provided solely to provide more information to the user. The Administration does not control or assume responsibility for the operation, content, privacy policies, or security of these sites.
6.5. If a user sends an email to the Administration containing information that allows identification or a question or comment, the Administration uses this information to meet the user’s requirements.
7. User Rights
7.1. The user has the right to receive information about the processing of personal data concerning him/her, including:
7.1.1. confirmation of the fact of processing personal data;
7.1.2. legal grounds for processing personal data;
7.1.3. purposes and methods of processing personal data used by the Administration;
7.1.4. information about individuals to whom personal data may be disclosed on the basis of a contract with the Administration or in accordance with the legislation of the Russian Federation;
7.1.5. other information provided by the legislation of the Russian Federation.
7.2. The user may revoke consent to the processing of personal data by deleting their account.
7.3. The user has the right to correct, supplement, and delete their personal data.
8. Responsibilities of the Administration
In accordance with the requirements of Serbian legislation, the Administration is obligated to:
8.1. Provide the User, upon request, with information concerning the processing of their personal data, or provide the User with a reasoned refusal.
8.2. Take necessary and sufficient measures to ensure compliance with the obligations provided for by Serbian legislation.
8.3. Clarify the processed personal data, block or delete them at the request of the User, if the personal data is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated processing purpose.
8.4. In the event of withdrawal of the User’s consent to the processing of personal data, stop processing and destroy personal data within thirty days from the date of receipt of the said withdrawal, except in cases where processing may continue in accordance with the legislation.
9. Limitation of Policy Scope
9.1. The Policy applies exclusively to the Site and does not apply to other websites.
9.2. The User is obligated to approach the placement of their own personal data on the Site in a reasonable and responsible manner. The Administration is not responsible for the actions of third parties who have gained access to the User’s personal data through the User’s fault.
10. Final Provisions
10.1. The text of the Policy is developed in accordance with the current legislation of Serbia on personal data.
10.2. The Administration has the right to make changes to the text of the Policy. When changes are made, the date of the last update is indicated in the current version. The Privacy Policy comes into force on April 21, 2023.
11. Contact Information and Administration Details
Company Name: THE LAND OF STRATEGIST D.O.O.
Address: Omladinskih Brigada 53, Belgrade, Serbia
Registration Number: 21818194
Tax Identification Number (TIN): 113180195
Beneficiary Bank: Raiffeisen banka ad Beograd
SWIFT (BIC) Code: RZBSRSBG
IBAN: RS35265100000058207908
Correspondent Bank: Raiffeisen Bank International AG, Vienna
SWIFT/BIC Code: RZBAATWW
Email Address: info@integralway.eu
