Džentlmen Ltd. Privacy Policy
Džentlmen Ltd. (hereinafter „we“ or „us“), with its registered office at Vojvođanska 385, Belgrade, Surčin, welcomes you to our website and mobile application (hereinafter „online offerings“). This notice describes how we use your personal data to enable you to use and benefit from our online offerings.
We collect and process personal data during your visit and use of our online offerings with trust and exclusively in accordance with the General Data Protection Regulation (GDPR) and the Personal Data Protection Law (ZZPL). Personal data includes all information related to an identifiable individual, such as personal name and surname, addresses, phone numbers, email addresses, photographs, or location.
1. Processing of Personal Data
We collect and process personal data that you provide to us via email and phone calls or when registering on the application and using our online offerings for the purpose of providing and improving our services. These data include names, contact information, as well as the role in the company or organization in which you or the person on whose behalf you contact us operates. In this case, Gentleman Ltd. is the controller of your data. We also process personal data obtained from third parties, acting as recipients of your personal data.
1.1 Payment Card and Transaction Data
For services used through our application, you can make payments using a payment card. We use and process payment card data and transaction data carried out through our application. For payment processing, we use the services of a third-party, WSpay, who holds a PCI DSS certificate guaranteeing transaction security and reliable crypto protection. We process transaction data, including transaction time, service usage fee, and GPS data. You have the right to access such data at any time.
1.2 Protection of Confidential Transaction Data
When entering credit card data, confidential information is transmitted over a public network in a secure (encrypted) form using the SSL protocol and PKI system, currently the most advanced cryptographic technology. The security of data during the purchase is guaranteed by the payment card processor. At no point are credit card details accessible to our system.
1.3 Service Fees of Gentleman Ltd.
The displayed price may vary due to changes in traffic, weather conditions, or modifications of the location specified by the user.
1.4 Conversion Statement
All payments will be effected in Serbian currency – Dinar (RSD). The amount your credit card account will be charged for is obtained through the conversion of the price in Euro into Serbian dinar according to the current exchange rate of the Serbian National Bank.
When charging your credit card, the same amount is converted into your local currency according to the exchange rate of credit card associations. As a result of this conversion there is a possibility of a slight difference from the original price stated in our web site.
1.5 Refund Policy
In the event of returning goods and refunding funds to a customer who has previously paid with a credit card, whether partially or in full, and regardless of the reason for the return, Džentlmen Ltd. is obligated to process the refund exclusively through VISA, EC/MC, and Maestro payment methods. This means that the bank, at the seller’s request, will initiate the refund to the user’s card account.
2. Purpose of Processing and Legal Basis
We primarily process personal data to provide, document, and invoice our services. We have a legitimate interest in processing personal data that corresponds to the stated purposes. We may process your personal data if it is necessary to fulfil our contractual obligations to you or our legal obligations. We process your personal data based on legitimate interest in accordance with the Personal Data Protection Law, or when your interest or fundamental rights and freedoms do not outweigh our legitimate interest. We use legitimate interest to maintain your user account, respond to your complaints and requests, protect the rights and property or safety of us, our employees, or other individuals, protect our business, prevent fraud and other unlawful actions, test and develop new services or improve existing ones.
Additionally, we process and collect contact data based on our legitimate interest for direct marketing (via communication channels such as email, social media, mail, or phone) to inform you about news, events, services, or products that may interest you. We collect, process, and use personal data (including IP addresses) only when there is a legal basis or when you have given us consent to process and use personal data, e.g., during registration, all that to fulfil our business purpose.
3. Recipients of Personal Data
To achieve the goals described in this privacy notice, it may be necessary to transfer some of your personal data to the following categories of data recipients: external service providers, external consultants, lawyers, business partners with whom we need to coordinate, as well as courts and authorities. We may disclose your personal data to any other recipient when reasonable and necessary, for example, in case of a threat to life.
3.1. Hosting and Cloud Services
Note that we rely on external IT service providers and cloud providers with servers in Switzerland. We also use certain IT services and communication tools that may pose a risk to data security (e.g., email, video conferences). It is your responsibility to inform us of your desire for specific security measures.
4. Transfer of Personal Data to Third Countries
We may transfer personal data to recipients processing data in third countries, including those that do not provide the same level of data protection as in the Republic of Serbia. We may transfer personal data without any protective measures if the recipient is in an EU country, if the recipient is in a country that is a signatory to Convention 108, or if the EU has determined that it provides an adequate level of protection. We may transfer personal data to third countries that do not provide the same level of data protection as in the Republic of Serbia only if you have given us consent or in accordance with signed standard contractual clauses, if necessary to fulfil our contractual or legal obligations.
5. Data Retention
We retain your personal data for as long as necessary to provide our services and related services or during the period in which we have a legitimate interest in data retention (e.g., direct marketing). We apply necessary precautions against the loss of personal data, unauthorized modifications, and access by third parties. If you want to provide us with personal data through a third party (employee or other contact person), you are obliged to inform them about the processing by legal entities (such as us) or other external service providers in the usual way (e.g., via the Privacy Notice for employees).
6. We Do Not Knowingly Collect Data from Minors Under 18
The application is not intended for individuals under the age of eighteen (18). We do not knowingly collect personal data from minors below this age. Any data subsequently found to originate from a minor will be deleted unless we have obtained consent from parents or guardians to collect their data. If a parent or guardian believes that their child has provided us with information and wants that data to be removed or corrected, please contact us at info@dzentlmentransport.com.
7. Cookies and Tracking Mechanisms
We use cookies and tracking mechanisms to enable you the usage of our online offerings and enhance your online experience on our website. Cookies are small text files that can be stored on your device when you visit or use our online services. We use cookies that are necessary for the technical functions of online offerings and cookies and tracking mechanisms that are not necessary for the technical functions of online offerings.
7.1. Cookies Necessary for Technical Functions of Online Offerings
Cookies necessary for technical reasons include all cookies that ensure the technical functioning of the application and website. These are, for example, cookies that store data enabling the playback of video or audio content. Such cookies are deleted after you leave the page.
7.2. Cookies and Tracking Mechanisms Not Necessary for Technical Functionality of Online Offerings
When using the application and website, we use marketing cookies and tracking mechanisms for statistical analysis of user behaviour and conversion tracking in order to improve our online offerings and optimize our services based on legitimate interest. We use such cookies only if you have previously given your consent.
7.3. Some marketing tools we use transmit your personal data to recipients in third countries where it is possible that there is no level of data protection in accordance with the Personal Data Protection Law and GDPR. Such tools include primarily tools provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA:
- Google Analytics – analyses user behaviour (number of visits and visitors, page searches, etc.), creates user profiles pseudonymously using information collected from multiple devices logged in by Google users, extends pseudonymous user data with information related to the target audience provided by Google, performs retargeting and UX testing, retargeting along with Google Ads, and tracks conversions.
- Google Tag Manager – manages website tags through the user interface, integrates program codes on our website.
- Google Ads – used for placing ads, remarketing, conversion tracking.
7.4. Cookie Management
You can manage cookies and tracking mechanisms in your browser settings and in our privacy settings. When visiting our website and using the application, we will ask you to give consent for the use of marketing cookies and tracking mechanisms. You can withdraw or give consent at any time. You can deactivate all cookies, including cookies necessary for technical functionality, in your browser settings. Note that this may prevent the proper functioning of the website and application.
8. Google
We use the following services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA:
- Google Maps – we use Google Maps services via API for the purpose of calculating the service price based on predefined tariffs, with the purpose of enabling the use of all the benefits of the website and application and achieving our legitimate business interest. To use Google Maps features, it is necessary to store your IP address, which Google LLC transmits to its server in the USA and stores there. Gentleman Ltd. has no influence on such data transfer.
- Google Fonts – we use Google Fonts to enable a uniform display of fonts. When you visit our online offerings, your browser loads the required web fonts into the memory of your browser to display texts and fonts uniformly, representing our legitimate interest under Article 12, Section 1, Point 6 of the Personal Data Protection Law.
9. Links to Third-Party Websites
Our online offerings may contain links to third-party websites and service providers not associated with us. If you click on a link, we cannot influence the collection, processing, and use of personal data that may be transmitted to a third party by clicking on the link (such as IP address or URL of the page where the link is located). In this case, the responsibility for processing, collecting, and using personal data is assumed by the entity whose page the link took you to.
10. VAT Statement
Džentlmen Ltd. doesn’t operate within the VAT system.
11. Complaints Policy
All users of our services have the right to file a complaint for non-compliance of the service, as well as for incorrectly calculated prices and other deficiencies, by sending an email to our official email address: info@dzentlmentransport.com. We will handle all complaints within the legally prescribed timeframes.
12. User Privacy Protection
We are committed to preserving the privacy of all our users.
We collect only the necessary, basic information about customers/users and data essential for business and informing users in accordance with good business practices and to provide quality service.
We provide customers with the option to choose, including the decision on whether they want to be removed from mailing lists used for marketing campaigns.
All customer/user data is strictly kept and only accessible to employees who require the information for performing their duties. All employees of Džentlmen Ltd (and business partners) are responsible for adhering to the principles of privacy protection.
13. Your Rights
All individuals whose data we collect and process have the right to know what personal data is being kept and for what purposes it is processed. They also have the right to request the deletion of their personal data or supplementation/correction, restriction of processing, withdrawal of consent, as well as the right to object to the supervisory authority and data portability. For questions or if you or your employees or other contacts wish to exercise your or their data protection rights, please contact us at info@dzentlmentransport.com. or write to Džentlmen Ltd., Vojvođanska 385, Belgrade, Surčin.
14. Change of the data protection notice
Džentlmen Ltd. reserves the right to change security measures and data protection at any time. Accordingly, the data protection notice will be changed, and it is advisable to regularly check our privacy policy to stay informed.
15. Consent and Withdrawal of Consent
You can withdraw your consent for the processing of your personal data given to us at any time. The request to withdraw consent can be sent to us at info@dzentlmentransport.com.
